1

CITY OF PH ILADELPHIA Department of Public Health

Environmental Protection Division Air Management Services

InterOffice Memo

To: File

From: Rahel Gebrekidan

Date: Dec 08, 2014

Subject: 1997 8-hour ozone RACT Summary fo r Newman and Company, Inc.



### Introduction:

The Clean Air Act (CAA) requires that mode rate (or worse) ozone nonattainment areas implement reasonably available control technolo gy (RACT) controls on all major sources of Volatile Organic Compounds (VOC) and Nitrogen Oxid es (NOx). Philadelphia County is part of the Philadelphia-Wilmington-Atlantic City mode rate ozone nonattainment area for the 1997 8- hour ozone NAAQS. This document presents the findings of a RACT evaluation for the 1997 8- hour ozone standard for this facility.



### Company Description:
Newman and Company, Inc. owns and operates a paperboard manufacturing facility located at 6101 Tacony Street, Philadelphia, PA 19135. The fac ility’s air emissions' sources include a 118 MMBTU/hr boiler (Boiler #1), twenty nine sp ace heaters less than 0.5 MMBTU/hr, and two power washers. The facility also has a stage II vapor recovery system for a 3,000 gallon gasoline, a 973,000 BTU/hr fire pump, and a trim waste blower system.



### Applicability for NOx RACT:
Newman and Company, Inc is a major source of NOx due to having potential emissions greater than 100 tons per year, the major source threshold in Philadelphia County th at is applicable to NOx RACT. This facility is not a major source of VOC having potential emissions less than 50 tons per year, the major source threshold in Ph iladelphia County that is applicable to VOC RACT for the 1997 8-hour ozone NAAQS.

The following are NOx emitting units in the facility : one (1) water tube boiler with a maximum heat input rating of 118 MMBTU per hour, firing natura l gas as its primary fuel and #6 fuel oil as auxiliary fuel (Boiler #1); twenty-nine (29) natural gas fired space heaters with less 500,000 BTU/hr heat capacity; two (2) natural gas fired power washer s with less 500,000 BTU/hr heat capacity; and one (1) 973,000 BTU/hr #2 oil burning fire pump.

Summary of 1-Hour RACT Determination AMS determined a case-by-case RACT for Boiler #1 for the 1-hour ozone standard. As a result of this case-by-case RACT determination, a 1-ho ur RACT plan approval (51-)3489 was issued on September 18, 1998 (effective on June 11, 1997), and approved in the SIP by EPA on October 30, 2001 (66 FR 54691).2

Emission limits for the 1-hour RACT for Boiler #1 are the following:

 0.43 lbs/MMBTU when firing #6 oil

 0.37 lbs/MMBTU when firing natural gas

 Total NOx emissions from the boiler may not exceed 121 tons per rolling 12-month period.
Newman demonstrates compliance with the abov e emission limits by performing stack test every five years.



### Case-by-case RACT Analysis:

Union Cogeneration Boiler (Boiler #1) The following section presents a detailed eval uation of Case-by-Case RACT for boiler#1 The Union Cogeneration boiler (Boiler #1) is a Union Iron Works wate r tube boiler with a maximum heat input rating of 118 MMBTU per hour . The boiler was installed in 1963 and fires natural gas as its primary fuel. The boiler is al so equipped to fire #6 fuel oil, as Newman’s contract for natural gas is interruptib le at the discretion of the utility. The boiler is equipped with supe r heaters to produce superheated steam to a steam turbine which can produce nearly 2 MW of electricity to the Mill.

Newman has issues in maintain safe and reliable operation at the full capacity of this boiler. In order to avoid refractory damage and furnace tube failure, Newman has limited the heat input of this Boiler to 95 MMBtu/hr through restrictions to fuel firing rate. This limitation has ensured that potential emissions of the Boiler remain lowe r than the emissions that would result from full load operation at full capacity and both the shor t term and annual emission limits are consistent with operation at the lower heat input capacity. The original lb/ MMBtu RACT limits and the tpy were based on stack testing at a load around th e 95 MMBTU/Hr rate. The st ack test data shows some variability in emission range between 0.23-0.345 lb/MMBTU while burning natural gas and 0.37-0.395 lb/MMBTU while burning No.6 fuel oil and lower emission limits cannot be achieved effectively wi thout add-on controls.

In addition to existing 1-hour approved RACT controls, other cont rol strategies that may be considered for Boiler #1 for NOx RACT are as follows:

Flue Gas Recirculation (FGR) The FGR to reduce NOx by an estimated 20% when firing natural gas; however, the FGR does not provide a benefit wh en firing #6 Fuel Oil. The design involves installing the foll owing equipment and modifications.

 FGR fan with VFD drive. The fan is required to overcome negative pressures in this balanced

draft boiler.

 Ductwork to the FGR fan.

 Ductwork from the FGR to the existing Com bustion Air Fan (FD Fan), including a manifold

on the fan inlet.

 Burner modifications to add a center fired gas gun for flame st ability. (The Boiler has three burners to modify)

 A VFD has already been insta lled on the FD Fan (60 hp)

 VFD and motor for the ID Fan (100 hp).

 Combustion control modifications. Technical Feasibility: This project is technically feasible3

Low NOx burners (LNB)/ Ultra Low NOx Burners

The manufacturer estimated that the new bur ners could reduce the NOx by 60%. However the project requires the replacement of the existing Natural Gas burners with Low NOx burners. The Low NOx burners would have staged combustion, thus changing the existi ng flame patterns with longer and wider flames. The Union Boiler was orig inally designed with a coal grate option and is designed with a shorter than usual furnace box. The combustion flames would most likely need to be angled upward, which is a different co nfiguration than the curr ent burner system. This would also change the flow of heat through the bo iler and is anticipated to potentially change the superheating capability of the boiler. The Low NOx burners may adversely affect the s uperheat capability of the boiler, which would

cause the same issues as described for Feedwater Economizer. Thus the Low NOx burners (LNB)/Ultra Low NOx Burners is consid ered to be technically infeasible.

The following NOx control was determined technologically feasible for the Boilers;

Economic Feasibility:

Control Technology Baseline NOx(tpy) NOx %

Reduction NOx

Reduction Total Annualized Cost Effectiveness ($/ton)

FGR 121* 20 24 85,535 3,564

Conclusion: The FGR is economically unreasonable.

* Federally enforceable emission limits per RACT NOx limit approved in the SIP by EPA on October 30, 2001.

The above control is determined economically unreasonable. For more detailed calculations, please see Appendix.

Conclusion

AMS has evaluated the above add-on controls and found it to be ec onomically/technically

infeasible and determines that the 1-hour ozone RACT determination, dated June 11, 1997 and SIP-approved by EPA on October 30, 2001 still be considered to represent NOx RACT for the

1997 8-hour ozone standard for Boiler #1. The boile r shall maintain the NOx emission limits not to exceed 0.43 lbs/MMBTU when firing #6 oil and 0.37 lbs/MMBTU when firing natural gas,

the total NOx emissions limit of 121 tons per rolling 12-month period.



### Presumptive RACT Sources
The following sources meet the various presump tive RACT emission limitations and criteria specified in 25 Pa. Code 129.93.

Table 1-1 lists sources that meet the presumptiv e RACT requirements specified in 25 Pa Code 129.93(c), operation and maintenance of boilers pe r manufacturer specifications, which are the following: the 29 space heaters and the 2 power washers.4

Table 1-1 Small space heaters

Source Capacity Fuel Type

Building No. 6 Space Heater 1 400,000 BTU/hr natural gas

Building No. 6 Space Heater 2 400,000 BTU/hr natural gas

Building No. 6 Space Heater 3 400,000 BTU/hr natural gas

Building No. 6 Space Heater 4 400,000 BTU/hr natural gas

Building No. 6 Space Heater 5 400,000 BTU/hr natural gas

Building No. 6 Space Heater 6 400,000 BTU/hr natural gas

Truck Shop Space Heater <500,000 BTU/hr natural gas

Truck Shop Space Heater <500,000 BTU/hr natural gas

Truck Shop Space Heater <500,000 BTU/hr natural gas

Truck Shop Space Heater <500,000 BTU/hr natural gas

Office Heater <500,000 BTU/hr natural gas

Shop Space Heater <500,000 BTU/hr natural gas

Powerhouse Space Heater <500,000 BTU/hr natural gas

Garage Space Heater <500,000 BTU/hr natural gas

Garage Space Heater <500,000 BTU/hr natural gas

Office Water Heater <500,000 BTU/hr natural gas

Mill Water Heater <500,000 BTU/hr natural gas

Mill Water Heater <500,000 BTU/hr natural gas

Power Washer - Shop <500,000 BTU/hr natural gas

Power Washer - Powerhouse <500,000 BTU/hr natural gas

USC Building Space Heater 1 <500,000 BTU/hr natural gas

USC Building Space Heater 2 <500,000 BTU/hr natural gas

USC Building Space Heater 3 <500,000 BTU/hr natural gas

USC Building Space Heater 4 <500,000 BTU/hr natural gas

Skid Shop Space Heater 1 <500,000 BTU/hr natural gas

Skid Shop Space Heater 2 <500,000 BTU/hr natural gas

Skid Shop Space Heater 3 <500,000 BTU/hr natural gas

Truck Shop Water Heater <500,000 BTU/hr natural gas

Building No. 6 Furnace <500,000 BTU/hr natural gas

USC Building Space Heater 5 <500,000 BTU/hr natural gas

USC Building Boiler 1 <500,000 BTU/hr natural gas

Table 1-2 identifies the presum ptive RACT requirement specif ied in 25 Pa Code 129.93(c)(5) [operation and maintenance of engines per manuf acturer specifications and use limited to 500 hours per year or less], that appl ies to the 973,000 BTU/hr fire pump.

Table 1-2 Fire Pump

Source Capacity Fuel Type
Ferman Warehouse Fire Pump 973,000 BTU/hr #2 Oil5

1 / 9 / 1 5

Edward Wiener, Chief of Source Registration Date6

Appendix

EPA Cost Manual, 6 th Edition , Jan 2002, Appendix A.2.3

3 Electricity cost : we assume 100 kw@ $0.08/kw-hr for one year. Reference PA DEP RACT State Implementation Plan (SIP) revision, Sep, 2006, page 18; EPA Cost Calculation, Appendix ANOx Control Analysis, A.1 Vendor In formation, A-2 Cost Calculation

4 From US Bureau of Labor Statics

o 5 Cost calculations for each elements are from references: North East States fo r Coordinated Air Use Management (NESCAUM), EPA' s Office of Air Quality Planning and standards

(OAQPS) edition 6, 2002; Cost analysis and engineering econo mics book (Michael R. Lindeburg), from Facility, and PADEP Guidelines for RACT SIP revision under the 8-hr Ozone7

NAAQS, Sep 2006 (Most elements of costs are taken fro m this doc of page 5 and 18) and from 1 Office of Air Quality Planning and standards (OAQPS) Environmental Protection Agency (EPA) Air Pollution Control Manual, Six Edition, EPA/452/B-02-001, Janua ry 2002 (page 2-27(2.5.5), I-52 table 1.13, Appendix A) and o ther States